Correspondence 0001213900-23-011451 from Primech Holdings Ltd (PMEC) (CIK 0001891944) (PMEC)
Primech Holdings Ltd (PMEC) (CIK 0001891944)
Date: Feb. 14, 2023 · CIK: 0001891944 · Accession: 0001213900-23-011451
AI Filing Summary & Sentiment
File numbers found in text: 333-264036
Referenced dates: February 10, 2023
Letter
United States Securities and Exchange Commission Division of Corporation Finance Office of Trade & Services Primech Holdings Pte. Ltd. Amendment No. 6 to Registration Statement on Form F-1 Filed January 31, 2023 File No. 333-264036
Dear Mr. Fetterolf and Ms. Jaskot:
On behalf of our client, Primech Holdings Pte. Ltd., a Singapore company (the “Company”), we respond to the comments of the staff of the Division of Corporation Finance of the Commission (the “Staff”) with respect to the above-referenced Registration Statement on Form F-1 filed on January 31, 2023 (the “Registration Statement”) contained in the Staff’s letter dated February 10, 2023 (the “Comment Letter”).
The Company has publicly filed an amendment number 7 to registration statement on Form F-1 (the “Amendment”) accompanying this response letter, which reflects the Company’s responses to the comments received by the Staff and certain updated information. For ease of reference, each comment contained in the Comment Letter is printed below and is followed by the Company’s response. All page references in the responses set forth below refer to the page numbers in the Registration Statement.
Amendment No. 6 to Registration Statement on Form F-1 filed January 31, 2023
Capitalization, page 45
1. Please tell us your consideration of including notes payable in the calculation of total capitalization.
Response: The Company has revised page 45 in response to the Staff’s comment.
Please do not hesitate to contact Lawrence Venick at (310) 728-5129 or Ted Paraskevas at (917) 974-3190 of Loeb & Loeb LLP with any questions or comments regarding this letter.
Sincerely,
/s/ Loeb & Loeb LLP
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Loeb & Loeb LLP
2206-19 Jardine House
1 Connaught Place Central
Hong Kong SAR
Direct
Main
Fax
+852-3923-1111
+852-3923-1111
+852-3923-1100
February 14, 2023
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Trade & Services
100 F Street, N.E.
Washington, D.C. 20549
Attn: Brian Fetterolf and Erin Jaskot
Re:
Primech Holdings Pte. Ltd.
Amendment No. 6 to Registration Statement on Form F-1
Filed January 31, 2023
File No. 333-264036
Dear Mr. Fetterolf and Ms. Jaskot:
On behalf of our client, Primech
Holdings Pte. Ltd., a Singapore company (the “Company”), we respond to the comments of the staff of the Division of Corporation
Finance of the Commission (the “Staff”) with respect to the above-referenced Registration Statement on Form F-1 filed on January
31, 2023 (the “Registration Statement”) contained in the Staff’s letter dated February 10, 2023 (the “Comment
Letter”).
The Company has publicly filed
an amendment number 7 to registration statement on Form F-1 (the “Amendment”) accompanying this response letter, which reflects
the Company’s responses to the comments received by the Staff and certain updated information. For ease of reference, each comment
contained in the Comment Letter is printed below and is followed by the Company’s response. All page references in the responses
set forth below refer to the page numbers in the Registration Statement.
Amendment No. 6 to Registration Statement on Form F-1 filed January
31, 2023
Capitalization, page 45
1. Please tell us your consideration of including notes payable in the calculation of total capitalization.
Response: The Company has revised
page 45 in response to the Staff’s comment.
Please do not hesitate to
contact Lawrence Venick at (310) 728-5129 or Ted Paraskevas at (917) 974-3190 of Loeb & Loeb LLP with any questions or comments regarding
this letter.
Sincerely,
/s/ Loeb & Loeb LLP
Loeb & Loeb LLP
cc: Mr. Ken Ho
Los Angeles New York Chicago Nashville Washington, DC San Francisco
Beijing Hong Kong www.loeb.com
For the United States offices, a limited liability partnership including
professional corporations. For Hong Kong office, a limited liability partnership.